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Changes Related to AP1000 Gts Subsection 3.4.18, Steam Generator Tube Integrity
ML22240A072
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Issue date: 05/27/2015
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Craig Harbuck NRR/DSS 301-415-3140
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GTST AP1000-O39-3.4.18, Rev. 1 Advanced Passive 1000 (AP1000)

Generic Technical Specification Traveler (GTST)

Title:

Changes Related to LCO 3.4.18, Steam Generator (SG) Tube Integrity I. Technical Specifications Task Force (TSTF) Travelers, Approved Since Revision 2 of STS NUREG-1431, and Used to Develop this GTST TSTF Number and

Title:

TSTF-449-A, Rev 4, Steam Generator Tube Integrity TSTF-510-A, Rev 2, Revision to Steam Generator Program Inspection Frequencies and Tube Sample Selection STS NUREGs Affected:

TSTF-449-A, Rev 4: NUREGs 1430, 1431, and 1432 TSTF-510-A, Rev 2: NUREGs 1430, 1431, and 1432 NRC Approval Date:

TSTF-449-A, Rev 4: 06-May-05 TSTF-510-A, Rev 2: 11-Oct-27 TSTF Classification:

TSTF-449-A, Rev 4: Technical Change TSTF-510-A, Rev 2: Technical Change Date report generated:

Wednesday, May 27, 2015 Page 1

GTST AP1000-O39-3.4.18, Rev. 1 II. Reference Combined License (RCOL) Standard Departures (Std. Dep.), RCOL COL Items, and RCOL Plant-Specific Technical Specifications (PTS) Changes Used to Develop this GTST RCOL Std. Dep. Number and

Title:

There are no Vogtle departures applicable to Specification 3.4.18.

RCOL COL Item Number and

Title:

There are no Vogtle COL items applicable to Specification 3.4.18.

RCOL PTS Change Number and

Title:

VEGP LAR DOC A008: Numerous TS surveillance frequencies are revised to add Once as the lead in VEGP LAR DOC A038: Numerous TS surveillances are revised by deletion of word that from the surveillance VEGP LAR DOC A064: GTS 3.4.17, Chemical and Volume Control System (CVS) Makeup Isolation Valves, is combined with STS 3.1.9 and GTS 3.4.18 is renumbered Date report generated:

Wednesday, May 27, 2015 Page 2

GTST AP1000-O39-3.4.18, Rev. 1 III. Comments on Relations Among TSTFs, RCOL Std. Dep., RCOL COL Items, and RCOL PTS Changes This section discusses the considered changes that are: (1) applicable to operating reactor designs, but not to the AP1000 design; (2) already incorporated in the GTS; or (3) superseded by another change.

TSTF-449-A has been applied to AP1000 GTS 3.4.18, Rev 19 by Westinghouse. TSTF-449-A will not be discussed further as a part of this GTST. The Federal Register Notice (FRN) of Availability reference for TSTF-449-A is Volume 70, No. 87, Friday, May 6, 2005 [Pages 24126-24127].

TSTF-510-A includes changes to NUREG-1431 that add optional SG repair criteria denoted by square brackets. Such SG repair criteria do not currently exist for AP1000 plants. Therefore, this GTST does not replace the phrase tube repair criteria with plugging [or repair] criteria; neither does it replace plugged with plugged [or repaired] where these terms occur in the LCO statement, Condition and Required Action statements, and Surveillance statements of GTS Subsection 3.4.18, nor in the LCO, Actions, and SRs sections of the Bases.

Date report generated:

Wednesday, May 27, 2015 Page 3

GTST AP1000-O39-3.4.18, Rev. 1 IV. Additional Changes Proposed as Part of this GTST (modifications proposed by NRC staff and/or clear editorial changes or deviations identified by preparer of GTST)

None Date report generated:

Wednesday, May 27, 2015 Page 4

GTST AP1000-O39-3.4.18, Rev. 1 V. Applicability Affected Generic Technical Specifications and Bases:

Section 3.4.18, Steam Generator (SG) Tube Integrity Changes to the Generic Technical Specifications and Bases:

GTS 3.4.18 is renumbered as STS 3.4.17 because GTS 3.4.17 is combined with STS 3.1.9.

(DOC A064)

GTS SR 3.4.18.2 is revised to remove that from SR statement. (A038)

GTS SR 3.4.18.2 is revised to add Once to the SR Frequency statement. (A008)

Date report generated:

Wednesday, May 27, 2015 Page 5

GTST AP1000-O39-3.4.18, Rev. 1 VI. Traveler Information Description of TSTF changes:

Not Applicable Rationale for TSTF changes:

Not Applicable Description of changes in RCOL Std. Dep., RCOL COL Item(s), and RCOL PTS Changes:

VEGP LAR DOC A008 revises GTS [STS] SR 3.4.18[17].2 is revised to add Once to the SR Frequency statement.

VEGP LAR DOC A038 revises GTS [STS] SR 3.4.18[17].2 by deleting that from the surveillance.

VEGP LAR DOC A064 combines GTS 3.4.17 with STS 3.1.9 and renumbers GTS 3.4.18 as STS 3.4.17.

A more detailed description of each DOC can be found in Reference 2, VEGP TSU LAR , and the NRC staff safety evaluation can be found in Reference 3, VEGP LAR SER. The VEGP TSU LAR was modified in response to NRC staff RAIs in Reference 5 and the Southern Nuclear Operating Company RAI Response in Reference 6.

Rationale for changes in RCOL Std. Dep., RCOL COL Item(s), and RCOL PTS Changes:

Editorial changes per VEGP LAR DOC A008 and DOC A038 are consistent with the guidance provided in the TS Writer's Guide (Reference 4).

VEGP LAR DOC A064 combines GTS 3.4.17 with STS 3.1.9. This requires GTS 3.4.18 to be renumbered as STS 3.4.17 to avoid a discontinuity in the TS numbering scheme.

Description of additional changes proposed by NRC staff/preparer of GTST:

Not Applicable Rationale for additional changes proposed by NRC staff/preparer of GTST:

Not Applicable Date report generated:

Wednesday, May 27, 2015 Page 6

GTST AP1000-O39-3.4.18, Rev. 1 VII. GTST Safety Evaluation Technical Analysis:

The changes are editorial, clarifying, grammatical, or otherwise considered administrative.

These changes do not affect the technical content, but improve the readability, implementation, and understanding of the requirements, and are therefore acceptable.

Having found that this GTSTs proposed changes to the GTS and Bases are acceptable, the NRC staff concludes that AP1000 STS Subsection 3.4.17 is an acceptable model Specification for the AP1000 standard reactor design.

References to Previous NRC Safety Evaluation Reports (SERs):

None Date report generated:

Wednesday, May 27, 2015 Page 7

GTST AP1000-O39-3.4.18, Rev. 1 VIII. Review Information Evaluator Comments:

STS (NUREG-1431) 3.4.20 is equivalent to AP1000 GTS 3.4.18 and AP1000 STS 3.4.17.

Randy Belles Oak Ridge National Laboratory 865-574-0388 bellesrj@ornl.gov Review Information:

Availability for public review and comment on Revision 0 of this traveler approved by NRC staff on 5/16/2014.

APOG Comments (Ref. 10) and Resolutions:

1. (Internal #7)Section VII, GTST Safety Evaluation, inconsistently completes the subsection References to Previous NRC Safety Evaluation Reports (SERs) by citing the associated SE for VEGP 3&4 COL Amendment 13. It is not clear whether there is a substantive intended difference when omitting the SE citation. This is resolved by removing the SE citation in Section VII of the GTST and ensuring that appropriate references to the consistent citation of this reference in Section X of the GTST are made.
2. (Internal #292) The GTST proposes changes based on TSTF-510 to GTS 3.4.18 in AP1000 STS 3.4.17. These changes reflect optional (i.e., bracketed) material applicable to SG repair criteria that does not currently exist for AP1000 plants. Since neither issued COL TS for VEGP or V.C. Summer include an NRC accepted licensing basis for SG repair, and since each represented AP1000 Utility is committed to maintaining standardization, there currently is no basis for an AP1000 STS that includes or repair options. At the time of a future submittal for NRC approval of repair criteria, the STS changes would also be appropriate to include at that time. Remove bracketed options for or repair. This is resolved by revising the TSTF-510 discussion in GTST Section III and deleting all descriptions of changes regarding SG tube optional repair criteria.

NRC Final Approval Date: 5/27/2015 NRC

Contact:

Hien Le United States Nuclear Regulatory Commission 301-415-1511 Hien.Le@nrc.gov Date report generated:

Wednesday, May 27, 2015 Page 8

GTST AP1000-O39-3.4.18, Rev. 1 IX. Evaluator Comments for Consideration in Finalizing Technical Specifications and Bases None Date report generated:

Wednesday, May 27, 2015 Page 9

GTST AP1000-O39-3.4.18, Rev. 1 X. References Used in GTST

1. AP1000 DCD, Revision 19, Section 16, Technical Specifications, June 2011 (ML11171A500).
2. Southern Nuclear Operating Company, Vogtle Electric Generating Plant, Units 3 and 4, Technical Specifications Upgrade License Amendment Request, February 24, 2011 (ML12065A057).
3. NRC Safety Evaluation (SE) for Amendment No. 13 to Combined License (COL) No.

NPF-91 for Vogtle Electric Generating Plant (VEGP) Unit 3, and Amendment No. 13 to COL No. NPF-92 for VEGP Unit 4, September 9, 2013, ADAMS Package Accession No. ML13238A337, which contains:

ML13238A355 Cover Letter - Issuance of License Amendment No. 13 for Vogtle Units 3 and 4 (LAR 12-002).

ML13238A359 Enclosure 1 - Amendment No. 13 to COL No. NPF-91 ML13239A256 Enclosure 2 - Amendment No. 13 to COL No. NPF-92 ML13239A284 Enclosure 3 - Revised plant-specific TS pages (Attachment to Amendment No. 13)

ML13239A287 Enclosure 4 - Safety Evaluation (SE), and Attachment 1 - Acronyms ML13239A288 SE Attachment 2 - Table A - Administrative Changes ML13239A319 SE Attachment 3 - Table M - More Restrictive Changes ML13239A333 SE Attachment 4 - Table R - Relocated Specifications ML13239A331 SE Attachment 5 - Table D - Detail Removed Changes ML13239A316 SE Attachment 6 - Table L - Less Restrictive Changes The following documents were subsequently issued to correct an administrative error in Enclosure 3:

ML13277A616 Letter - Correction To The Attachment (Replacement Pages) - Vogtle Electric Generating Plant Units 3 and 4-Issuance of Amendment Re:

Technical Specifications Upgrade (LAR 12-002) (TAC No. RP9402)

ML13277A637 Enclosure 3 - Revised plant-specific TS pages (Attachment to Amendment No. 13) (corrected)

4. TSTF-GG-05-01, Writer's Guide for Plant-Specific Improved Technical Specifications, June 2005.
5. RAI Letter No. 01 Related to License Amendment Request (LAR)12-002 for the Vogtle Electric Generating Plant Units 3 and 4 Combined Licenses, September 7, 2012 (ML12251A355).
6. Southern Nuclear Operating Company, Vogtle Electric Generating Plant, Units 3 and 4, Response to Request for Additional Information Letter No. 01 Related to License Amendment Request LAR-12-002, ND-12-2015, October 04, 2012 (ML12286A363 and ML12286A360)

Date report generated:

Wednesday, May 27, 2015 Page 10

GTST AP1000-O39-3.4.18, Rev. 1

7. APOG-2014-008, APOG (AP1000 Utilities) Comments on AP1000 Standardized Technical Specifications (STS) Generic Technical Specification Travelers (GTSTs), Docket ID NRC-2014-0147, September 22, 2014 (ML14265A493).

Date report generated:

Wednesday, May 27, 2015 Page 11

GTST AP1000-O39-3.4.18, Rev. 1 XI. MARKUP of the Applicable GTS Subsection for Preparation of the STS NUREG The entire section of the Specifications and the Bases associated with this GTST is presented next.

Changes to the Specifications and Bases are denoted as follows: Deleted portions are marked in strikethrough red font, and inserted portions in bold blue font.

Date report generated:

Wednesday, May 27, 2015 Page 12

GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity 3.4.178 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.178 Steam Generator (SG) Tube Integrity LCO 3.4.178 SG tube integrity shall be maintained.

AND All SG tubes satisfying the tube repair criteria shall be plugged in accordance with the Steam Generator Program.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

NOTE-----------------------------------------------------------

Separate Condition entry is allowed for each SG tube.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SG tubes A.1 Verify tube integrity of the 7 days satisfying the tube repair affected tube(s) is criteria and not plugged maintained until the next in accordance with the refueling outage or SG tube Steam Generator inspection.

Program.

AND A.2 Plug the affected tube(s) in Prior to entering accordance with the Steam MODE 4 following the Generator Program. next refueling outage or SG tube inspection AP1000 STS 3.4.178-1 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 13

GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity 3.4.178 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR SG tube integrity not maintained.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.178.1 Verify SG tube integrity in accordance with the Steam In accordance Generator Program. with the Steam Generator Program SR 3.4.178.2 Verify that each inspected SG tube that satisfies the Once pPrior to tube repair criteria is plugged in accordance with the entering MODE 4 Steam Generator Program. following a SG tube inspection AP1000 STS 3.4.178-2 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 14

GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.178 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.178 Steam Generator (SG) Tube Integrity BASES BACKGROUND Steam generator (SG) tubes are small diameter, thin walled tubes that carry primary coolant through the primary to secondary heat exchangers.

The SG tubes have a number of important safety functions. Steam generator tubes are an integral part of the reactor coolant pressure boundary (RCPB) and, as such, are relied on to maintain the primary systems pressure and inventory. The SG tubes isolate the radioactive fission products in the primary coolant from the secondary system. In addition, as part of the RCPB, the SG tubes are unique in that they act as the heat transfer surface between the primary and secondary systems to remove heat from the primary system. This Specification addresses only the RCPB integrity function of the SG. The SG heat removal function is addressed by LCO 3.4.4, RCS Loops.

SG tube integrity means that the tubes are capable of performing their intended RCPB safety function consistent with the licensing basis, including applicable regulatory requirements.

Steam generator tubing is subject to a variety of degradation mechanisms. Steam generator tubes may experience tube degradation related to corrosion phenomena, such as wastage, pitting, intergranular attack, and stress corrosion cracking, along with other mechanically induced phenomena such as denting and wear. These degradation mechanisms can impair tube integrity if they are not managed effectively.

The SG performance criteria are used to manage SG tube degradation.

Specification 5.5.4, Steam Generator (SG) Program, requires that a program be established and implemented to ensure that SG tube integrity is maintained. Pursuant to Specification 5.5.4, tube integrity is maintained when the SG performance criteria are met. There are three SG performance criteria: structural integrity, accident induced leakage, and operational LEAKAGE. The SG performance criteria are described in Specification 5.5.4. Meeting the SG performance criteria provides reasonable assurance of maintaining tube integrity at normal and accident conditions.

The processes used to meet the SG performance criteria are defined by the Steam Generator Program Guidelines (Ref. 1).

AP1000 STS B 3.4.178-1 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 15

GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.178 BASES APPLICABLE The steam generator tube rupture (SGTR) accident is the limiting design SAFETY basis event for SG tubes and avoiding an SGTR is the basis for this ANALYSES Specification. The analysis of a SGTR event assumes a bounding primary to secondary LEAKAGE rate equal to the operational LEAKAGE rate limits in LCO 3.4.7, RCS Operational LEAKAGE, plus the leakage rate associated with a double-ended rupture of a single tube. The accident analysis for a SGTR assumes the contaminated secondary fluid is only briefly released to the atmosphere via safety valves and the majority is discharged to the main condenser.

The analysis for design basis accidents and transients other than a SGTR assume the SG tubes retain their structural integrity (i.e., they are assumed not to rupture.) In these analyses, the steam discharge to the atmosphere includes primary to secondary SG tube LEAKAGE equivalent to the operational leakage limit of 150 gpd per SG. For accidents that do not involve fuel damage, the primary coolant activity level of DOSE EQUIVALENT I-131 is assumed to be equal to the LCO 3.4.10, RCS Specific Activity, limits. For accidents that assume fuel damage, the primary coolant activity is a function of the amount of activity released from the damaged fuel. The dose consequences of these events are within the limits of GDC 19 (Ref. 2), 10 CFR 50.34 (Ref. 3) or the NRC approved licensing basis (e.g., a small fraction of these limits).

Steam generator tube integrity satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requires that SG tube integrity be maintained. The LCO also requires that all SG tubes that satisfy the repair criteria be plugged in accordance with the Steam Generator Program.

During an SG inspection, any inspected tube that satisfies the Steam Generator Program repair criteria is removed from service by plugging. If a tube was determined to satisfy the repair criteria but was not plugged, the tube may still have tube integrity.

In the context of this Specification, a SG tube is defined as the entire length of the tube, including the tube wall, between the tube-to-tubesheet weld at the tube inlet and the tube-to-tubesheet weld at the tube outlet.

The tube-to-tubesheet weld is not considered part of the tube.

AP1000 STS B 3.4.178-2 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 16

GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.178 BASES LCO (continued)

A SG tube has tube integrity when it satisfies the SG performance criteria. The SG performance criteria are defined in Specification 5.5.4, Steam Generator Program, and describe acceptable SG tube performance. The Steam Generator Program also provides the evaluation process for determining conformance with the SG performance criteria.

There are three SG performance criteria: structural integrity, accident induced leakage, and operational LEAKAGE. Failure to meet any one of these criteria is considered failure to meet the LCO.

The structural integrity performance criterion provides a margin of safety against tube burst or collapse under normal and accident conditions, and ensures structural integrity of the SG tubes under all anticipated transients included in the design specification. Tube burst is defined as, The gross structural failure of the tube wall. The condition typically corresponds to an unstable opening displacement (e.g., opening area increased in response to constant pressure) accompanied by ductile (plastic) tearing of the tube material at the ends of the degradation.

Tube collapse is defined as, For the load displacement curve for a given structure, collapse occurs at the top of the load versus displacement curve where the slope of the curve becomes zero. The structural integrity performance criterion provides guidance on assessing loads that have a significant effect on burst or collapse. In that context, the term significant is defined as An accident loading condition other than differential pressure is considered significant when the addition of such loads in the assessment of the structural integrity performance criterion could cause a lower structural limit or limiting burst/collapse condition to be established. For tube integrity evaluations, except for circumferential degradation, axial thermal loads are classified as secondary loads. For circumferential degradation, the classification of axial thermal loads as primary or secondary loads will be evaluated on a case-by-case basis.

The division between primary and secondary classifications will be based on detailed analysis and/or testing.

Structural integrity requires that the primary membrane stress intensity in a tube not exceed the yield strength for all ASME Code,Section III, Service Level A (normal operating conditions) and Service Level B (upset or abnormal conditions) transients included in the design specification.

This includes safety factors and applicable design basis loads based on ASME Code,Section III, Subsection NB (Ref. 4) and Draft Regulatory Guide 1.121 (Ref. 5).

AP1000 STS B 3.4.178-3 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 17

GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.178 BASES LCO (continued)

The accident induced leakage performance criterion ensures that the primary to secondary LEAKAGE caused by a design basis accident, other than a SGTR, is within the accident analysis assumptions. The accident analysis assumes that accident induced leakage does not exceed 150 gpd per SG. The accident induced leakage rate includes any primary to secondary LEAKAGE existing prior to the accident in addition to primary to secondary LEAKAGE induced during the accident.

The operational LEAKAGE performance criterion provides an observable indication of SG tube conditions during plant operation. The limit on operational LEAKAGE is contained in LCO 3.4.7, RCS Operational LEAKAGE, and limits primary to secondary LEAKAGE through any one SG to 150 gallons per day. This limit is based on the assumption that a single crack leaking this amount would not propagate to a SGTR under the stress conditions of a LOCA or a main steam line break. If this amount of LEAKAGE is due to more than one crack, the cracks are very small, and the above assumption is conservative.

APPLICABILITY Steam generator tube integrity is challenged when the pressure differential across the tubes is large. Large differential pressures across SG tubes can only be experienced in MODE 1, 2, 3, or 4.

RCS conditions are far less challenging in MODES 5 and 6 than during MODES 1, 2, 3, and 4. In MODES 5 and 6, primary to secondary differential pressure is low, resulting in lower stresses and reduced potential for LEAKAGE.

ACTIONS The ACTIONS are modified by a Note clarifying that the Conditions may be entered independently for each SG tube. This is acceptable because the Required Actions provide appropriate compensatory actions for each affected SG tube. Complying with the Required Actions may allow for continued operation, and subsequent affected SG tubes are governed by subsequent Condition entry and application of associated Required Actions.

AP1000 STS B 3.4.178-4 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 18

GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.178 BASES ACTIONS (continued)

A.1 and A.2 Condition A applies if it is discovered that one or more SG tubes examined in an inservice inspection satisfy the tube criteria but were not plugged in accordance with the Steam Generator Program as required by SR 3.4.1718.2. An evaluation of SG tube integrity of the affected tube(s) must be made. Steam generator tube integrity is based on meeting the SG performance criteria described in the Steam Generator Program.

The SG repair criteria define limits on SG tube degradation that allow for flaw growth between inspections while still providing assurance that the SG performance criteria will continue to be met. In order to determine if a SG tube that should have been plugged has tube integrity, an evaluation must be completed that demonstrates that the SG performance criteria will continue to be met until the next refueling outage or SG tube inspection. The tube integrity determination is based on the estimated condition of the tube at the time the situation is discovered and the estimated growth of the degradation prior to the next SG tube inspection. If it is determined that tube integrity is not being maintained, Condition B applies.

A Completion Time of 7 days is sufficient to complete the evaluation while minimizing the risk of plant operation with a SG tube that may not have tube integrity.

If the evaluation determines that the affected tube(s) have tube integrity, Required Action A.2 allows plant operation to continue until the next refueling outage or SG inspection provided the inspection interval continues to be supported by an operational assessment that reflects the affected tubes. However, the affected tube(s) must be plugged prior to entering MODE 4 following the next refueling outage or SG inspection.

This Completion Time is acceptable since operation until the next inspection is supported by the operational assessment.

B.1 and B.2 If the Required Actions and associated Completion Times of Condition A are not met or if SG tube integrity is not being maintained, the reactor must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the desired plant conditions from full power conditions in an orderly manner and without challenging plant systems.

AP1000 STS B 3.4.178-5 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 19

GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.178 BASES SURVEILLANCE SR 3.4.1718.1 REQUIREMENTS During shutdown periods the SGs are inspected as required by this SR and the Steam Generator Program. NEI 97-06, Steam Generator Program Guidelines (Ref. 1), and its referenced EPRI Guidelines, establish the content of the Steam Generator Program. Use of the Steam Generator Program ensures that the inspection is appropriate and consistent with accepted industry practices.

During SG inspections a condition monitoring assessment of the SG tubes is performed. The condition monitoring assessment determines the as found condition of the SG tubes. The purpose of the condition monitoring assessment is to ensure that the SG performance criteria have been met for the previous operating period.

The Steam Generator Program determines the scope of the inspection and the methods used to determine whether the tubes contain flaws satisfying the tube repair criteria. Inspection scope (i.e., which tubes or areas of tubing within the SG are to be inspected) is a function of existing and potential degradation locations. The Steam Generator Program also specifies the inspection methods to be used to find potential degradation.

Inspection methods are a function of degradation morphology, non-destructive examination (NDE) technique capabilities, and inspection locations.

The Steam Generator Program defines the Frequency of SR 3.4.1718.1.

The Frequency is determined by the operational assessment and other limits in the SG examination guidelines (Ref. 6). The Steam Generator Program uses information on existing degradations and growth rates to determine an inspection Frequency that provides reasonable assurance that the tubing will meet the SG performance criteria at the next scheduled inspection. In addition, Specification 5.5.4 contains prescriptive requirements concerning inspection intervals to provide added assurance that the SG performance criteria will be met between scheduled inspections.

SR 3.4.1718.2 During an SG inspection, any inspected tube that satisfies the Steam Generator Program repair criteria is removed from service by plugging.

The tube repair criteria delineated in Specification 5.5.4 are intended to ensure that tubes accepted for continued service satisfy the SG performance criteria with allowance for error in the flaw size measurement and for future flaw growth. In addition, the tube repair AP1000 STS B 3.4.178-6 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 20

GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.178 BASES SURVEILLANCE REQUIREMENTS (continued) criteria, in conjunction with other elements of the Steam Generator Program, ensure that the SG performance criteria will continue to be met until the next inspection of the subject tube(s). Reference 1 provides guidance for performing operational assessments to verify that the tubes remaining in service will continue to meet the SG performance criteria.

The Frequency of once prior to entering MODE 4 following a SG inspection ensures that the Surveillance has been completed and all tubes meeting the repair criteria are plugged prior to subjecting the SG tubes to significant primary to secondary pressure differential.

REFERENCES 1. NEI 97-06, Steam Generator Program Guidelines.

2. 10 CFR 50 Appendix A, GDC 19.
3. 10 CFR 50.34.
4. ASME Boiler and Pressure Vessel Code,Section III, Subsection NB.
5. Draft Regulatory Guide 1.121, Basis for Plugging Degraded Steam Generator Tubes, August 1976.
6. EPRI, Pressurized Water Reactor Steam Generator Examination Guidelines.

AP1000 STS B 3.4.178-7 Amendment 0Rev. 0 Revision 19 Date report generated:

Wednesday, May 27, 2015 Page 21

GTST AP1000-O39-3.4.18, Rev. 1 XII. Applicable STS Subsection After Incorporation of this GTSTs Modifications The entire subsection of the Specifications and the Bases associated with this GTST, following incorporation of the modifications, is presented next.

Date report generated:

Wednesday, May 27, 2015 Page 22

GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity 3.4.17 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.17 Steam Generator (SG) Tube Integrity LCO 3.4.17 SG tube integrity shall be maintained.

AND All SG tubes satisfying the tube repair criteria shall be plugged in accordance with the Steam Generator Program.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

NOTE-----------------------------------------------------------

Separate Condition entry is allowed for each SG tube.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more SG tubes A.1 Verify tube integrity of the 7 days satisfying the tube repair affected tube(s) is criteria and not plugged maintained until the next in accordance with the refueling outage or SG tube Steam Generator inspection.

Program.

AND A.2 Plug the affected tube(s) in Prior to entering accordance with the Steam MODE 4 following the Generator Program. next refueling outage or SG tube inspection AP1000 STS 3.4.17-1 Rev. 0 Date report generated:

Wednesday, May 27, 2015 Page 23

GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity 3.4.17 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A not AND met.

B.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR SG tube integrity not maintained.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.17.1 Verify SG tube integrity in accordance with the Steam In accordance Generator Program. with the Steam Generator Program SR 3.4.17.2 Verify each inspected SG tube that satisfies the tube Once prior to repair criteria is plugged in accordance with the Steam entering MODE 4 Generator Program. following a SG tube inspection AP1000 STS 3.4.17-2 Rev. 0 Date report generated:

Wednesday, May 27, 2015 Page 24

GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.17 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.17 Steam Generator (SG) Tube Integrity BASES BACKGROUND Steam generator (SG) tubes are small diameter, thin walled tubes that carry primary coolant through the primary to secondary heat exchangers.

The SG tubes have a number of important safety functions. Steam generator tubes are an integral part of the reactor coolant pressure boundary (RCPB) and, as such, are relied on to maintain the primary systems pressure and inventory. The SG tubes isolate the radioactive fission products in the primary coolant from the secondary system. In addition, as part of the RCPB, the SG tubes are unique in that they act as the heat transfer surface between the primary and secondary systems to remove heat from the primary system. This Specification addresses only the RCPB integrity function of the SG. The SG heat removal function is addressed by LCO 3.4.4, RCS Loops.

SG tube integrity means that the tubes are capable of performing their intended RCPB safety function consistent with the licensing basis, including applicable regulatory requirements.

Steam generator tubing is subject to a variety of degradation mechanisms. Steam generator tubes may experience tube degradation related to corrosion phenomena, such as wastage, pitting, intergranular attack, and stress corrosion cracking, along with other mechanically induced phenomena such as denting and wear. These degradation mechanisms can impair tube integrity if they are not managed effectively.

The SG performance criteria are used to manage SG tube degradation.

Specification 5.5.4, Steam Generator (SG) Program, requires that a program be established and implemented to ensure that SG tube integrity is maintained. Pursuant to Specification 5.5.4, tube integrity is maintained when the SG performance criteria are met. There are three SG performance criteria: structural integrity, accident induced leakage, and operational LEAKAGE. The SG performance criteria are described in Specification 5.5.4. Meeting the SG performance criteria provides reasonable assurance of maintaining tube integrity at normal and accident conditions.

The processes used to meet the SG performance criteria are defined by the Steam Generator Program Guidelines (Ref. 1).

AP1000 STS B 3.4.17-1 Rev. 0 Date report generated:

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GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.17 BASES APPLICABLE The steam generator tube rupture (SGTR) accident is the limiting design SAFETY basis event for SG tubes and avoiding an SGTR is the basis for this ANALYSES Specification. The analysis of a SGTR event assumes a bounding primary to secondary LEAKAGE rate equal to the operational LEAKAGE rate limits in LCO 3.4.7, RCS Operational LEAKAGE, plus the leakage rate associated with a double-ended rupture of a single tube. The accident analysis for a SGTR assumes the contaminated secondary fluid is only briefly released to the atmosphere via safety valves and the majority is discharged to the main condenser.

The analysis for design basis accidents and transients other than a SGTR assume the SG tubes retain their structural integrity (i.e., they are assumed not to rupture.) In these analyses, the steam discharge to the atmosphere includes primary to secondary SG tube LEAKAGE equivalent to the operational leakage limit of 150 gpd per SG. For accidents that do not involve fuel damage, the primary coolant activity level of DOSE EQUIVALENT I-131 is assumed to be equal to the LCO 3.4.10, RCS Specific Activity, limits. For accidents that assume fuel damage, the primary coolant activity is a function of the amount of activity released from the damaged fuel. The dose consequences of these events are within the limits of GDC 19 (Ref. 2), 10 CFR 50.34 (Ref. 3) or the NRC approved licensing basis (e.g., a small fraction of these limits).

Steam generator tube integrity satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requires that SG tube integrity be maintained. The LCO also requires that all SG tubes that satisfy the repair criteria be plugged in accordance with the Steam Generator Program.

During an SG inspection, any inspected tube that satisfies the Steam Generator Program repair criteria is removed from service by plugging. If a tube was determined to satisfy the repair criteria but was not plugged, the tube may still have tube integrity.

In the context of this Specification, a SG tube is defined as the entire length of the tube, including the tube wall, between the tube-to-tubesheet weld at the tube inlet and the tube-to-tubesheet weld at the tube outlet.

The tube-to-tubesheet weld is not considered part of the tube.

AP1000 STS B 3.4.17-2 Rev. 0 Date report generated:

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GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.17 BASES LCO (continued)

A SG tube has tube integrity when it satisfies the SG performance criteria. The SG performance criteria are defined in Specification 5.5.4, Steam Generator Program, and describe acceptable SG tube performance. The Steam Generator Program also provides the evaluation process for determining conformance with the SG performance criteria.

There are three SG performance criteria: structural integrity, accident induced leakage, and operational LEAKAGE. Failure to meet any one of these criteria is considered failure to meet the LCO.

The structural integrity performance criterion provides a margin of safety against tube burst or collapse under normal and accident conditions, and ensures structural integrity of the SG tubes under all anticipated transients included in the design specification. Tube burst is defined as, The gross structural failure of the tube wall. The condition typically corresponds to an unstable opening displacement (e.g., opening area increased in response to constant pressure) accompanied by ductile (plastic) tearing of the tube material at the ends of the degradation.

Tube collapse is defined as, For the load displacement curve for a given structure, collapse occurs at the top of the load versus displacement curve where the slope of the curve becomes zero. The structural integrity performance criterion provides guidance on assessing loads that have a significant effect on burst or collapse. In that context, the term significant is defined as An accident loading condition other than differential pressure is considered significant when the addition of such loads in the assessment of the structural integrity performance criterion could cause a lower structural limit or limiting burst/collapse condition to be established. For tube integrity evaluations, except for circumferential degradation, axial thermal loads are classified as secondary loads. For circumferential degradation, the classification of axial thermal loads as primary or secondary loads will be evaluated on a case-by-case basis.

The division between primary and secondary classifications will be based on detailed analysis and/or testing.

Structural integrity requires that the primary membrane stress intensity in a tube not exceed the yield strength for all ASME Code,Section III, Service Level A (normal operating conditions) and Service Level B (upset or abnormal conditions) transients included in the design specification.

This includes safety factors and applicable design basis loads based on ASME Code,Section III, Subsection NB (Ref. 4) and Draft Regulatory Guide 1.121 (Ref. 5).

AP1000 STS B 3.4.17-3 Rev. 0 Date report generated:

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GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.17 BASES LCO (continued)

The accident induced leakage performance criterion ensures that the primary to secondary LEAKAGE caused by a design basis accident, other than a SGTR, is within the accident analysis assumptions. The accident analysis assumes that accident induced leakage does not exceed 150 gpd per SG. The accident induced leakage rate includes any primary to secondary LEAKAGE existing prior to the accident in addition to primary to secondary LEAKAGE induced during the accident.

The operational LEAKAGE performance criterion provides an observable indication of SG tube conditions during plant operation. The limit on operational LEAKAGE is contained in LCO 3.4.7, RCS Operational LEAKAGE, and limits primary to secondary LEAKAGE through any one SG to 150 gallons per day. This limit is based on the assumption that a single crack leaking this amount would not propagate to a SGTR under the stress conditions of a LOCA or a main steam line break. If this amount of LEAKAGE is due to more than one crack, the cracks are very small, and the above assumption is conservative.

APPLICABILITY Steam generator tube integrity is challenged when the pressure differential across the tubes is large. Large differential pressures across SG tubes can only be experienced in MODE 1, 2, 3, or 4.

RCS conditions are far less challenging in MODES 5 and 6 than during MODES 1, 2, 3, and 4. In MODES 5 and 6, primary to secondary differential pressure is low, resulting in lower stresses and reduced potential for LEAKAGE.

ACTIONS The ACTIONS are modified by a Note clarifying that the Conditions may be entered independently for each SG tube. This is acceptable because the Required Actions provide appropriate compensatory actions for each affected SG tube. Complying with the Required Actions may allow for continued operation, and subsequent affected SG tubes are governed by subsequent Condition entry and application of associated Required Actions.

AP1000 STS B 3.4.17-4 Rev. 0 Date report generated:

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GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.17 BASES ACTIONS (continued)

A.1 and A.2 Condition A applies if it is discovered that one or more SG tubes examined in an inservice inspection satisfy the tube criteria but were not plugged in accordance with the Steam Generator Program as required by SR 3.4.17.2. An evaluation of SG tube integrity of the affected tube(s) must be made. Steam generator tube integrity is based on meeting the SG performance criteria described in the Steam Generator Program.

The SG repair criteria define limits on SG tube degradation that allow for flaw growth between inspections while still providing assurance that the SG performance criteria will continue to be met. In order to determine if a SG tube that should have been plugged has tube integrity, an evaluation must be completed that demonstrates that the SG performance criteria will continue to be met until the next refueling outage or SG tube inspection. The tube integrity determination is based on the estimated condition of the tube at the time the situation is discovered and the estimated growth of the degradation prior to the next SG tube inspection. If it is determined that tube integrity is not being maintained, Condition B applies.

A Completion Time of 7 days is sufficient to complete the evaluation while minimizing the risk of plant operation with a SG tube that may not have tube integrity.

If the evaluation determines that the affected tube(s) have tube integrity, Required Action A.2 allows plant operation to continue until the next refueling outage or SG inspection provided the inspection interval continues to be supported by an operational assessment that reflects the affected tubes. However, the affected tube(s) must be plugged prior to entering MODE 4 following the next refueling outage or SG inspection.

This Completion Time is acceptable since operation until the next inspection is supported by the operational assessment.

B.1 and B.2 If the Required Actions and associated Completion Times of Condition A are not met or if SG tube integrity is not being maintained, the reactor must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the desired plant conditions from full power conditions in an orderly manner and without challenging plant systems.

AP1000 STS B 3.4.17-5 Rev. 0 Date report generated:

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GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.17 BASES SURVEILLANCE SR 3.4.17.1 REQUIREMENTS During shutdown periods the SGs are inspected as required by this SR and the Steam Generator Program. NEI 97-06, Steam Generator Program Guidelines (Ref. 1), and its referenced EPRI Guidelines, establish the content of the Steam Generator Program. Use of the Steam Generator Program ensures that the inspection is appropriate and consistent with accepted industry practices.

During SG inspections a condition monitoring assessment of the SG tubes is performed. The condition monitoring assessment determines the as found condition of the SG tubes. The purpose of the condition monitoring assessment is to ensure that the SG performance criteria have been met for the previous operating period.

The Steam Generator Program determines the scope of the inspection and the methods used to determine whether the tubes contain flaws satisfying the tube repair criteria. Inspection scope (i.e., which tubes or areas of tubing within the SG are to be inspected) is a function of existing and potential degradation locations. The Steam Generator Program also specifies the inspection methods to be used to find potential degradation.

Inspection methods are a function of degradation morphology, non-destructive examination (NDE) technique capabilities, and inspection locations.

The Steam Generator Program defines the Frequency of SR 3.4.17.1.

The Frequency is determined by the operational assessment and other limits in the SG examination guidelines (Ref. 6). The Steam Generator Program uses information on existing degradations and growth rates to determine an inspection Frequency that provides reasonable assurance that the tubing will meet the SG performance criteria at the next scheduled inspection. In addition, Specification 5.5.4 contains prescriptive requirements concerning inspection intervals to provide added assurance that the SG performance criteria will be met between scheduled inspections.

SR 3.4.17.2 During an SG inspection, any inspected tube that satisfies the Steam Generator Program repair criteria is removed from service by plugging.

The tube repair criteria delineated in Specification 5.5.4 are intended to ensure that tubes accepted for continued service satisfy the SG performance criteria with allowance for error in the flaw size measurement and for future flaw growth. In addition, the tube repair AP1000 STS B 3.4.17-6 Rev. 0 Date report generated:

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GTST AP1000-O39-3.4.18, Rev. 1 SG Tube Integrity B 3.4.17 BASES SURVEILLANCE REQUIREMENTS (continued) criteria, in conjunction with other elements of the Steam Generator Program, ensure that the SG performance criteria will continue to be met until the next inspection of the subject tube(s). Reference 1 provides guidance for performing operational assessments to verify that the tubes remaining in service will continue to meet the SG performance criteria.

The Frequency of once prior to entering MODE 4 following a SG inspection ensures that the Surveillance has been completed and all tubes meeting the repair criteria are plugged prior to subjecting the SG tubes to significant primary to secondary pressure differential.

REFERENCES 1. NEI 97-06, Steam Generator Program Guidelines.

2. 10 CFR 50 Appendix A, GDC 19.
3. 10 CFR 50.34.
4. ASME Boiler and Pressure Vessel Code,Section III, Subsection NB.
5. Draft Regulatory Guide 1.121, Basis for Plugging Degraded Steam Generator Tubes, August 1976.
6. EPRI, Pressurized Water Reactor Steam Generator Examination Guidelines.

AP1000 STS B 3.4.17-7 Rev. 0 Date report generated:

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